34 | Sector Focus: Joinery
REGULATION CHANGE IMPACT TO FIRE
DOORS AND STAIRS
British Woodworking Federation technical director Kevin Underwood explores the possible effects of building regulation guidance change and gives the BWF’s response to ongoing consultation on proposals
for example, that the FD30 and FD30S classifications for fire doors, which are based on BS 476 testing, will be withdrawn. DLUHC proposes a 12-month transition period to allow industry to implement the changes. The consultation also focuses on staircases in residential buildings. Due to concern around tall residential buildings with one staircase, DLUHC is proposing a second staircase in new residential buildings over 30m in height and, while there will be a short transition period, it is encouraging developers to prepare for this change now.
Above: A certified fire door
The Department for Levelling Up, Housing and Communities (DLUHC) has recently consulted the industry on proposed changes to England’s building regulations guidance with significant impacts for fire doors and stairs.
For fire doors, DLUHC proposes removal of national classification standards from Approved Document B. During the Grenfell Tower Inquiry use of the national classification standards for reaction to fire and fire resistance in Approved Document B came under scrutiny, with criticism focused on the BS 476 series national classifications for reaction to fire. This resulted in DLUHC removing the reference to all national classifications from the main body of Approved Document B in 2019, and only including them in the annexes.
Now DLUHC plans to remove the remaining references to all aspects of the BS 476 series from Approved Document B. This will mean,
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Beyond fire doors and stairs, the proposed changes also include potential revisions to Approved Document B 10.6 and 10.7 which restrict the combustibility of insulation materials used on external walls. DLUHC is considering revising these paragraphs to improve and clarify guidance. Several of these changes would have a significant impact on BWF members and it has responded to the consultation to highlight key concerns on behalf of the woodworking and joinery manufacturing sector. A key part of the BWF’s response focused on our view that national classifications for fire resistance should not be removed from Approved Document B. The BWF Fire Door Alliance members, whose products are third-party certified, lean heavily on national classifications for testing, with around 90% testing to BS 476-22 while only 10% use EN 1634-1.
Not only would removal of national classifications result in a significant increase in demand for testing that could overwhelm the system, it would mean the cost of retesting products would fall on organisations that may not be in a position to fund an extensive and expensive R&D and testing programme.
In turn, this could result in businesses considering whether the costs justify remaining in the market while also opening the market up to European competition,
which could further impact UK fire door manufacturers.
In addition, the transition raises further questions surrounding CE or UKCA conformity marking, which is only currently required for external fire doors supplied as doorsets.
As well as disagreeing with the proposal,
the BWF said if the changes go ahead the transition period would need to be at least 60 months – five times DLUHC’s initial suggestion. This would help alleviate backlogs at already congested testing facilities and give businesses adequate time to adjust. With regards to the proposed staircase changes, the BWF voiced its support, but shared its view that they should be implemented at three storeys or heights of 11m or more. This would align with the point at which a single escape stair in a residential building is required to have a reaction to fire class A2-s3, d2 or better. We also shared our support for sprinklers becoming recommended in care homes, while highlighting the need for fire doors to ensure compartmentalisation to support sprinkler performance.
For the woodworking and joinery sector, if the proposed changes are implemented as intended, it will have significant effects on businesses. Now is the time for businesses to consider the impact on their manufacturing process and supply chain, and seek further advice and guidance. At the BWF, we are awaiting response to the consultation and will release further information and insight for our members based on updates from the DLUHC. ■
FURTHER INFORMATION
For more information on the BWF’s response to the DLUHC consultation, visit:
https://www.bwf.org.uk/
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